Question of the Week: Calculating Generator Status
A. Each and every person who produces hazardous waste is a generator and must determine his or her generator status each calender month. A facility’s generator status determines how stringently it is regulated and how long it may accumulate hazardous waste on site without a permit.
Three Categories of Waste Generator
Conditionally Exempt Small Quantity Generators (CESQGs) generate no more than 100 kilograms of hazardous waste per calender month [40 CFR 261.5(a)]. CESQGs are largely exempt from regulation, as long as they classify their waste and ensure that it is recycled or disposed of in an appropriate facility.
Small Quantity Generators (SQGs) generate more than 100 kilograms but less than 1,000 kilograms of hazardous waste per calender month [40 CFR 262.34(d)]. SQGs may accumulate hazardous waste on site without a permit for up to 180 days [40 CFR 262.34(d)].
Large Quantity Generators (LQGs) generate 1,000 kilograms or more of hazardous waste per calender month. LQGs may accumulate hazardous waste on-site without a permit for up to 90 days and have more paperwork obligations than SQGs [40 CFR 262.34(a)].
Don’t Count Wastes Not Subject to Substantive Regulation
As the following waste materials are not subject to substantive regulation, they do not count when calculating generator status:
- Hazardous waste in manufacturing process units [40 CFR 261.4(c)]
- Hazardous waste or tractability study samples [40 CFR 261.4(d), (e), (f)]
- Ethyl alcohol, scrap metal, or petroleum refining wastes when recycled [40 CFR 261.6(a)(3)]
- Empty hazardous waste containers [40 CFR 261.7(a)(1)]
- Polychlorinated biphenyl (PCB) wastes managed under TSCA [40 CFR 261.8]
- Hazardous wastes managed immediately on site in elementary neutralization units, wastewater treatment units, or totally enclosed treatment facilities [40 CFR 261.5(c)(2)]
- Hazardous wastes recycled immediately without prior storage in an on-site process subject to 40 CFR 261.5(c)(3)
- Used oil, spent lead-acid batteries, and universal wastes when managed under specific regulations [40 CFR 261.5(c)(4), (5), and (6)]
- Wastes generated in laboratory cleanouts under 40 CFR Part 262 Subpart K [40 CFR 261.5(c)(7)]
Generators must count their waste at the point of generation and should not re-count the same waste during the same calender month. This means that generators should NOT count when wastes are removed from a satellite accumulation area to a central accumulation area or when wastes are shipped off site. [40 CFR 261.5(d)]
If a generator reclaims hazardous waste for reuse on site, then the product and residues from the reclamation process do not count towards the generator status, as long as the hazardous waste was counted before reclamation. If the same stock of material is continually reused, then the generator must “count” the waste once a month [40 CFR 261.5(d)].
Find a Post
Best instructor ever! I was going to take my DOT training w/a different provider, but based on this presentation, I will also be doing my DOT training w/Lion!
Hazardous Waste Professional
I was able to present my scenario to the instructor and worked thru the regulations together. In the past, I attended another training firm's classes. Now, I have no intention of leaving Lion!
Senior Environmental Engineer
We have a very busy work schedule and using Lion enables us to take the course at our own time. It makes it easy for me to schedule my employees' training.
Hazmat Shipping Professional
The instructor was probably the best I ever had! He made the class enjoyable, was humorous at times, and very knowledgeable.
Mary Sue Michon
I can't say enough how pleased I was with this course! Everything finally makes sense.
Our instructor was very dynamic and kept everyone's interest. Hazmat shipping can be a dry, complicated topic but I was engaged the entire time.
Senior Director of EH&S
The instructor clearly enjoys his job and transmits that enthusiasm. He made a dry subject very interesting and fun.
Excellent. I learned more in two days with Lion than at a 5-day program I took with another provider.
Very good. I have always appreciated the way Lion Tech develops, presents and provides training and materials.
This training broke down the regulations in an easy-to-understand manner and made them less overwhelming. I now feel I have the knowledge to make more informed decisions.
Download Our Latest Whitepaper
Hazardous materials shipment rejections bear a big cost. Use this guide to end operational and logistical disruptions that severely impact your bottom line.